1 9 7 9 I='all M e e t i n g

T e c h n i c a l C o m m i t t e e D o c u m e n t a t i o n

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A Cm~pilation of the Documented Action on Comments Received by the Technical Committees Whose Reports Have Been Published

Prior to Consideration at the NFPA Fall Meeting

Hyatt Regency Phoenix Phoenix, Arizona

November 12-14, 1979

I Please Bring to the Fall Meeting I

N F P A

Copyright ~ 1979 All Rights Reserved

National Fire Protection Association, Inc. ,470 Atlantic Avenue, Boston, MA 02210

11M-9-79-FP-SM Printed m U.$ A.

SUPPLEMENTARY

Report of Committee on Liquefied Natural Gas

James H. Stannard, Jr., Chairman Stannard and Company

Basking Ridge, New Jersey

W. L. Walls, Secretary National Fire Protection Association

(Nonvoting)

Donald S. Allan, Arthur D. L i t t le Frank J. Ayers, Consolldated Edison of NY

(Rep. American Gas Association) David Burgess, U. S. Bureau of Mines J. B. Butler, Mobil Research & Development Corp.

(Rep. American Petroleum Institute) John J. Callahan, Rhode Island Public Ut i l i t ies Commission

John A. Davenport, Industrial Risk Insurers Joseph Dolan, Boston Fire Department

(Rep. Fire Marshals Association of North America) Lawrence Douglas, Ansul Co.

(Rep. Fire Equipment Manufacturers Association) William H. Doyle, Simsbury, CT

Dwight A. Dundore, Philadelphia Gas Works (Rep. American Gas Association)

Richard M. Gibson, Factory Mutual Research Corp. (Rep. American Society of Mechanical Engineers)

Richard A. Hoffmann, Hoffmann & Feige Inc.

Oliver W. Johnson, Ph.D., Palo Alto, CA I. V. LaFave, Chicago Bridge & Iron Co.

(Rep. Steel Plate Fabricators Association) Wallace D. Malmstedt, American Insurance Assoclation R. M. Neary, Union Carbide Corp.

(Rep. Cow~vressed Gas Association) W. H. Penn, Tennessee Gas Pipeline Co.

(Rep. American Gas Association) James J. Regan, Starr Technical Risks Agency Henry C. Scuoteguazza, Factory Mutual Research Corp.

F. E. Sellm, Phil l ips Petroleum Co. (Rep. American Petroleum Instltute)

E. C. Semmer, Exxon Research & Engineering Co. (Rep. American Petroleum Institute)

Ira C. Stanfi11, Memphis Light-Gas & Water Dlvislon (Rep. American Gas Association)

Lt. Ronald W. Tanner, U. S. Coast Guard

Frank Wolff, American Air Liquide, Inc. (Rep. Compressed Gas Association)

G. E. Deering, American Petroleum Institute (Alternate to J. Butler, F. Selim, E. Sommer)

Leonard R. Devanna, San Diego Gas & Electric Company (Alternate to F. Ayers, D. Dundore, W. Penn, I. Stanf l l l )

Victor G. Geihsler, Industrial Risk Insurers (Alternate to J. A. Davenport)

Alternates

Arne Hansen, Safety First Products Corp. (Alternate to L. Douglas)

John T. McKenna, Jr., Boston Gas Company (Alternate to F. Ayers, D. Dundore, W. Penn, I. Stanf i l l )

Robert C. Merritt, Factory Mutual Research Corp. (Alternate to H. C. Scuoteguazza)

Nonvoting

R. G. Blakely, British Columbia Hydro-Power Dr. E. B. Graham, British Gas Corporation (Rep. Canadian Standards Assn. Comm. on Liq. Natural Gas) (Rep. Institute of Gas Engineers)

E. M. Foo, Trans Canada Pipeline Co. (Rep. Canadian Standards Assn. Comm. on Liq. Natural Gas)

This l i s t represents the membership at the time the Conmlttee was balloted on this report. Since that time changes in the membership may have occurred.

The Committee on Liquefied Natural Gas proposes for adoption this Supplementary Report which documents its action on public comments received on the proposed revision to NFPA 5gA-Ig75, Standard for the Production, Storage and Handling of Liquefied Natural Gas (LNG) as publlshed in the Technical Committee Reports for the Ig7g Fall Meeting.

This Supplementary Report has been submitted to Letter Ballot of the Committee on Liquefied Natural Gas which consists of 25 voting members; of whom 22 have voted affirmatively on the Report. The Messrs. Davenport, Douglas and Neary did not return their ballots.

5gA-1 - (2110): Reject SUBMITTER: Joel Anderson, Southern Energy Company ~ A T I O N : Revise as follows: 2110, Impounding areas serving LNG containers shall have a minimum volumetric holding capacity, V, including any useful holding capacity of the drainage area and with allowance made for the displacement of snow accumulation, other containers and equipment, ~n accordance with 2110(a) through (c). SUBSTANTIATION: I f s~ow accumulation is going to be considered, some means to calculate a da~ly average wil l be required. COMMITTEE ACTION: Reject intent. COMMITTEE COMMENT: Commentor has simply stated 2110 as i t would ~e i f TCR Proposal B9A-3 is adopted. Therefore, he has • recommended no change. Considering intent, however, the Committee considers i t to be ~mpractical to quantify such a site specific factor as snow accumulation.

59A-2 - (2113): Reject SUBMITTER: Howard W. Patt] l lo, A~r Products and Chemlcals, Inc. ~ A T I O N : Delete the proposed changes and add the following as the last sentence: "Penetrations for any purpose are prohlbited." SUBSTANTIATION: Penetrations in dikes add to the potential for LNG to flow beyond the containment. W~th proven re l iab i l i ty of submerged pumps, bottom penetration of tanks and'penetration of dikes are no, longer requlred. In addition, water can readily be pumped from the containment without the use of gravity drains. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment 4. '

59A-3 - (2113): Reject SUBMITTER: Max M. Levy, Columbia LNG Corporation

RE-R-E~FORI~F£-~-DATION: Revise as foTlows: 2113. Dikes, ~mpounding walls and drainage channels for LNG and flammable refrigerant containment shall be compacted earth, concrete, metal and/or other suitable materlals. They may be independent of the container or they may be mounded, integral to, or constructed against the container. They, and any penetrations thereof, shall be designed to withstand the ful l hydrostatic head of impounded LNG or flammable refrigerant, the effect of rapid coollhg to the temperature of the liquid to be conflned, any antlcipated f l re exposure, and natural forces such as earthquake, wind and rain. Thin wall outer shells of double wall tanks shall not be considered as satisfying the requirements of 2100. Penetrations for any purpose other than water drainage or LNG and LNG vapor plp~ng are prohibited. SUBSTANTIATION: El~mlnation of dlke penetrations for any service has no engineering design justif ication. The NFPA committee is obviously not intending to eliminate penetrations but to arbitrarl ly limit thelr number. The proposed amendment should be changed to include at least LNG vapor lines. There ]s no justif ication in this case to l imit the engineer's options by prohibiting a penetration which can be designed to meet or exceed the other requirements of paragraph 2113. COMMITTEE ACTION: Reject.

COMMITTEE COMMENT: See Comment 4.

59A-4 - (2113): Accept SUBMITTER: E. C. Sommer, Exxon Research & Englneerlng Co. RECO~ATION: Delete proposed new last sentence, "Penetrations for any purpose...". SUBSTANTIATION: See no reason why electrical and ~nstrument c a b l ~ m p l e , cannot be run through dike~ or impoundlng walls (such as permltted for water drainage and LNG piping) i f such cables meet all the requirements of 2113. Use of buried cables Is a pOsltlve means of protecting them from f lre or cold exposure. Running cables overhead would require some type of flreproofing that Is less ~oslt~ve protectlon. I f drainage and LNG plping can be installed to meet 2113 what is the reason that determlnes cables or other components cannot slmilarly be safely installed? Performance standards should be equally applled. Furthermore, thls requirement would be applicable to all Impound]ng walls including those that may be provided for flammable llqulds or refrlgerants or to impound spllls or leaks from piping. This broad appllcatlon would be d i f f icu l t to comply wlth wlthout any safety beneflt. For example, a pump within a toe wall to impound any liquid sp111 would requlre electric cables to run aboveground untll outside the impounding area. I t would also prohlblt installatlon of a flammable llqu]d l~ne through the impounding area serwng a flammable l~qu]d tank but would permit an LNG line to run through the same impounding wall. There ~s no logic to th~s requlrement other than the performance standard set up ~n the other parts of 2113.

ICOMMITTEE ACTION: Accept. Delete added sentence (only). "~-OMMITTE E cONMENT: Deletion of added sentence recommended ifi TCR Propdsal 59A-4 w~ll s t i l l require penetrations to comply with cri teria for dlkes, ~mpound~ng walls and drainage channels i f TCR Proposal is adopted as amended in Supplementary Report. W~th thls stlpulat]on, Committee believes that character of penetrations permitted should be studied further.

59A-5 - (Chapter 2, Paragraph 2113, last sentence): Reject SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas ~ o n of America RECOMMENDATION: Proposed:

"Penetrations for any purpose other than LNG or water drainage piping are prohibited."

Recommended Change: "Penetratlons for any purpose other than water dralnage or LNG

piplng are prohibited." SUBSTANTIATION: I t is not believed the authors intended to imply that LNG drainage piping was to be incorporated in an impounded area. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment 4.

59A-6 - (2113): Hold for further study SUBMITTER: B. H. Bakerjian, Public Service Electric and Gas Company RECOMMENDATION: Delete the last sentence and replace with the following:

"Thin wall outer shells of multlple wall tanks may be considered as satisfying the requirements of 2100 provided that by deslgn they can meet the same crlteria as that for the primary component." SUBSTANTIATION: The present wording appears to be written for the conventional double wall tank whlch has a cryogenlc inner tank and carbon steel outer tank. Double walled prestressed concrete tanks with or without a reinforced concrete berm or a double-walled tank with both walls of cryogenic materlal with or wlthout a reinforced concrete berm could satisfy the requirements of 2100 with proper design. COMMITTEE ACTION: Hold for further study. COMMITTEE COMMENT: Recommendatlon introduces a concept which has not had public review.

59A-7 - (Figure 2-I): Accept SUBMITTER: B. H. Bakerjlan, Public Service Electric and Gas ~pany RECOMMENDATION: Add the following exceptlop to the end of the proposed recommendation:

" . . . . . except when the helght of the dik.e or impoundin~ wall is equal to, or greater than the maximum llquld level, "X" may have any value." SUBSTANTIATION: The free fal l of a llquid stream cannot by definition rise above the liquid level. Therefore, when the height of the dike or impoundlng wall is equal to or greater than the maximum llquid level, there is no way for the free-falllng stream~to rise above its own level. Gas pressure could extend the trajeCtory but not make the free-falling stream r~se, therefore, ~n such a case the "X" dimension could be any value.

I COMMITTEE ACTION: Accept.

Add second sentence to TCR Proposal 59A-6 to read: "Exception: When the height . . . . " remainder as proposed by

Submltter. COMMITTEE COMMENT: Amendment i~ consistent with and clarlfles Committee intent.

59A-8 - (2117): Hold for further study SUBMITTER: Howard W. Patt i l lo, Air Products and Chemicals, Inc. ~ A T I O N : Add the following sentence: 'tAn annual inspection or test shall be conducted to verify the integrlty of the system." S_UBSTANTIATION: Insulatlon systems deteriorate when subjected to the elements and loss of integrity would reduce the effectlveness of the system. A requirement to conduct an annual inspection or test would as a mlnimum polnt out a weakness ~n the system. COMMITTEE ACTION: Hold for further study. COMMITTEE COMMENT: Recommendation introduces a concept which has not had public review.

59A-9 - (2117-New): Reject SUBMITTER: Max M. Levy, Columbia LNG Corporation ~ A T I O N : Revlse as follows: 2117. Insulation systems used for impounding surfaces shall be sultable for the intended service considerlng the antlclpated thermal and mechanlcal stresses and loadings, I f f lotation is a problem, mitigating measures shall be provided. In the installed condition, the insulation'system shall not propagate a f l re. SUBSTANTIATION: I t is arbitrari ly restrictive to require insulation systems for impounding surfaces to be noncombustible. The intent of the insulation system is, in the event of an LNG leak, to restrlct the heat flow into the impounded LNG and thereby maintaln a low rate of vapor generation. The insulation system should be such that i f the impounding system is involved in a f i re , the insulation should

30

not propagate the f l re to an area previously uninvolved. I t ]s not the intent to have the Insulation system protect the ~mpoundlng system from the effects of a f i re , therefore the nonco~bustible requirement is unnecessary. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Whlle the ~ntent of the Subm~tter's Proposal and the Committees' appear to be the same, the Con~lttee feels that, ~n practice, rehable accomphshment can be achieved only i f the systems are noncombustible in the ~nstalled condition.

59A-10 - (Chapter 2, Paragraph 2117): Reject SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas ~ o n of America RECOMMENDATION: Proposed:

" . . . i n the installed condition, noncoefoustible...% Recommended Change: Delete "noncombustible" Substitute: "self extlnguishing"

SUBSTANTIATION: The word "noncombustible" would preclude the use of "self extinguishing" materials which are c o , only used. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment 9. Further, the term "self extinguishing" is undefinable in the installed condition.

I t is also unrealistic to attempt to provlde an ~deal r~skless environment. Ever)thing we as a people do ~nvolves some rlsk, a good exan~ole ~s the thousands of people who are k111ed each year In automobiles. As an ~ndustr~al natlon and as a people we know this is a risk which we must l~ve w~th in order to have the avai labi l l ty and convenience of the automobile. I t ~s a practical balance between risk, convenlence and need. The same obJectlve should be applied to thermal f lux crlter~a for s~t~ng LNG plants. By deleting part (a) we can accompl~sh th~s. What we would recommend IS a flux level of 1600 BTU/Hr-Ft2 at the property l~ne for places of outdoor assembly (50 people or more) where shelter Is not readlly available and people would not generally wear clothing and thus not have the shielding ~t provides; a f lux level of 3,000 BTU/Hr-Ft2 at the property llne for structures which house s~ck or hand~capped (people not in control of thelr mob11~ty) s~nce the structure would provide shielding and therefore t~me to evacuate and 10,000 BTU/Hr-Ft2 at the property l~ne for all other structures. COMMITTEE ACTION: Reject. COMMITTEE COfi~4ENT: Submltter has apparently confused the ~deslgn spi l l " criterion ~n 2120(a) wlth the ful l ~mpoundlng area sp~11s cited In 2120(b)-(d). The Committee feels that the 1600 Btu/hr/sq.ft. thermal flux specified ~s real~stic ~n terms of the more rapidly developlng design spi l l .

59A-11 - (2117-New): Reject SUBMITTER: B. H. Bakerjlan, Pubhc Service Electric and Gas ~'~ompany RECOMMENDATION: Add a superscript 1 immediately after the word "noncombustible" ~n the second hne and add footnote as follows:

(1) Refer to paragraph 6102 for explanation of properties intended by use of this term. SUBSTANTIATION: There ~s no defln~tion of the word Nnoncoe~oustible" and therefore could lead to d~fferences in interpretation. New paragraph 6102 appears to satisfy the intent of the new 2117 paragraph. CO~IMITTEE ACTION: Reject. COMMITTEE CO~I~ENT: Because of the term "installed condlt~on," there may be great d~fferences in flame propagation behavior between insulation on piping and insulatlon on impounding area surfaces. While "noncombustible" is not defined in NFPA 59A, i t is defined in other NFPA standards - e.g., NFPA 220 - and ~s a generally recognized term in f i re protection engineering practice.

59A-14 - (2120(a)): Reject SUBMITTER: B. H. Bakerjlan, Public Service Electric and Gas Company RECOMMENDATION: Between the words "lgnltlon" and "of" add the. phrase " . . . . . from the llquid pool . . . . . ". Change the referenced paragraph 2121 to 2122. Between the words "upon ~ and "when" add the phrase "----outslde the owner's property llne . . . . . ". SUBSTANTIATION: I t should be very clear to the reader Just what the condltlons are which must be met. Therefore, ] t was fe l t necessary to r~late the LNG pool and not a vapor cloud resultlng from a release w~th respect to the nearest polnt outslde the owner's property line. Also the reference to 2121 is ~ncorrect s~nce proposed change 59A-I0 changes the reference to 2122. COMMITTEE ACTION: Reject technical recommendation. Change "2121" to "2122". COMMITTEE COMMENT: Wording in TCR Proposal 59A-8 parallels wording that has been in the standard for several years with no reported ~nterpretive problems. Committee sees no point ~n changing this at this time.

The reference should be to Paragraph 2122.

59A-12 - (2120): Reject SUBMITTER: B. H. Bakerjlan, Publlc Serwce Electric and Gas i~--ompany RECOMMENDATION: Add the following ~ntroductory sentence:

"The fac i l i t y shall be designed such that i t meets the distance requirements of d I through d4 below". SUBSTANTIATION: The reader should not have to assume which of the distances is required to be met. A simple concisestatement can avoid any question in the future by the reader, Further, I t should not be assumed that every reader is knowledgeable and therefore clar i fy Is of the utmost importance. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Com~entors' proposal would require that the formulae be used. Intent of 2120 is to require compliance with certain basic cr i ter ia (2120(a)-(d)) and that formulae 1A-ID may be used to meet these cri terla.

59A-15 - (Chapter 2, Paragraph 2120(b)): Reject SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas ~ o n of A~rlca RECOMMENDATION: Proposed:

"...groups of 50 or more persons when atmospheric condltions are zero wind speed, 21C (70=F) temperature and 50 percent relative humidity."

Recom~nded Change: "...groups of 50 or more persons. Calculations shall be made

when atmospberlc conditions are zero wlnd speed..." SUBSTANTIATION: Enhances the meaning. C(]~I~ITTEE ACTION" Reject. COMMITTEE COf4MENT: The wordlng in TCR Proposal SgA-8 seems at least as clear as that proposed by the Subm~tter. I t Is noted that parallel sentence structure is also used in 2120(a), (c) and (d).

59A-13 - (2120(a)): Reject SUBMITTER: Richard Scholz, Consolldated Edison Co. of New

RECOI~4ENDATION: Delete. SUBSTANTIATION: The context of this revision assumes that a leak wil l instantly f i l l an impounding area, be instantly i~jnlted and, further, assumes that there will be no protection to people beyond that of a distance to the property hne. This is an impossib111ty since there Is a time factor involved before an accidental sp111 becomes a major hazard to h i e and property. Time for people to take cover and tlme to place greater distance between themselves and the f i re . Obwously there w111 be a time delay before having an intense f l re over an entlre impounding area, such that a 1600 BTU/Hr-Ft2 thermal f lux vapor is extremely conservative. However, since OPSO and probably the Coast Guard have indicated they could accept 1600 BTU/Hr-Ft2 as a minlmu~ and speciflcally for areas of outdoor assembly of 50 people or mere, this conservative thermal flux should be adopted for areas of outdoor assembly; therefore part (b) of the proposed revision is acceptable. I t is recommended, however, that part (a) be deleted in its entirety. To reem~haslze the point we must refer back to NFPA comments to OPSO which stated that u,..thermal f lux levels.., can be achieved only i f the radlant f lux is very hlgh and pool actually reaches its maximum dimens]on and recept~vlty of the target Is near unity. The simultaneous occurrence of all three Is extremely unllkely".

59A-16 - (2120(c))" Reject SUBMITTER: Max M. Levy, Columbia LNG Corporatlon RECOMMENDATION: Revise as follows:

(c) Provlslon shall be made to prevent a radlatlon flux from a f l re over an impoundlng area from exceedlng 12000 W/m2 (4000 8tu/hr/ft2) at the nearest polnt of a bullding or structure in exlstence at the time of plant sitlng and used for purposes class~fled by NFPA 101, Life Safety Code,* 1976, as Assembly, Educatlonal, Health Care, Penal or Residentlal when atmospherlc cond~tlons are zero wlnd speed, 21°C (70°F) temperature, and SO percent rela~ive humldlty. Thls provlsion may be complled with by a separation dlstance determlned by Formula 1C. SUBSTANTIATION: The heat flux level has been changed to 12,000 W/m2 (4000 Btu/hr/ft2) slnce that is the cr i t ical or threshold intenslty requlred for p11oted ign~tlon of most celluloslc materlals (Ref. "Calculatlons of Thermal Radlat~on Hazards from LNG Fires - A Revlew of the State of the Art," P.P.K. Ra3, May 18, 1977).

This value is conslstent wlth AGA accepted flgures and wlth the value proposed by Materials Transportatlon Bureau DOT in their Notlce of Proposed Rulemaking - 49 CFR Part 193. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee intent is to ~et a f lux level below that cited in some 11terature as required for the piloted ignltion of wood and other celluloslc materials. Whlle conservative, i t ~s believed reasonable cons~derlng the nature of the exposures covered by proposed 2120(c).

31

59A-17 - (Chapter 2, Paragraph 2120(c)): Reject SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas ~ o n of America RECOMMENDATION: Proposed:

"...impounding area from e~ceeding 9000 W/m2 (3000 Btu/hr/ft.2)...,,

Recommended Change: "...impounding area from exceedlng 12,000 W/m2 (4000

Btu/hr/ft.2)...,, SUBSTANTIATION: Radiant heat fluxes of 1,600 and 4,000 Btu/hr/ft2 are taken from acknowledged references in the f leld of LNG thermal radiation, specifically "Calculation of Thermal Radiation Hazards from LNG Fires - A Review of the State of the Art" by Mr. Phani Raj, Arthur D. L i t t le , Inc., presented at the May 18, 1977 American Gas Associatipn Conference. COMMITTEE ACTION: Reject. ~OMMiYTEE CbMMENT: See Comment 16.

59A-2~ ~-- (2121(e)): Accept in part SUBMITTER: Joel Anderson, Southern Energy Company ~ A T I O N : Revise as follows: 2121(e) The presence of methods for detaining the vapor formed as a result of spills or otherwise mitigating the hazard - e.g., ~mpounding surface insulation, water curtalns, and/or high expansion foam - may be consldered provided there exists demonstrable surveillance and functional provisions acceptable to the authority having jurisdiction. SUBSTANTIATION: Although the present wording does not exclude high expansion foam, i t should be listed also for the sake of clari ty. Also, the present wordlng implies that credit can be taken for surface insulation or water curtains, but not both. This should be clarif ied so that credit can be taken for all methods installed to mitigate the vapor travel. COMMITTEE ACTION: Accept in part. ~MITTEE COMMENT: See Comment 23.

59A-18 - (2120(c)): Accept SUBMITTER: B. H. Bakerjian, Public Service Electric and Gas ~pany RECOMMENDATION: Between the words "structure" and "in", add the • phrase " . . . . outside the owner's property line . . . . '!. SUBSTANTIATION: As worded, buildings inside the owner's property line could be included in the various structures enumerated. This would be an unreasonable restriction. I t is assumed that the intent of the separation distance is between

i the impoundment and structures outside the owner's property line. COMMITTEEIACTION: Accept.

I . Amend 2120(b) by adding "outside the owner's property line" between "place" and "which".

2. Amend 2120(c) by adding "outside the owner's property line" between "structure" and "in". COMMITTEE COMMENT: Clarifles Committee intent.'Applicable to 2120(b) also.

59A-19 - (2120(e) New): Reject SUBMITTER: Joel Anderson, Southern Energy Company ~ A T I O N : Add a Sectlon 2120(e) as follows:

"Use of these formulas to determine separatlon dlstances is not mandatory. The option exlsts for either determination of separation distances by calculation or to employ f i re radlation control methods other than separation distances alone, provided that all prowsions of 2120 are met." SUBSTANTIATION: The present wording implies that these formulas are not mandatory, but for the sake of clar i ty i t should be explicit ly stated. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Committee proposal wording is conslstent with that in past editlons and no interpretive problems have been reported.

59A-20 - (2121(d)): Accept SUBMITTER: Howard W. Patt i l lo, Air Products and Chemlcals, Inc. ~ A T I O N : Change the proposed wording from " in i t ia l vapor outflow" to "maximum vapor outflow." SUBSTANTIATION: The in i t ia l vapor outflow, although probably close to maximum, may not be maximum. The method used in the calculation should be based on maximum vapor outflow slnce the intent is to minimize the poss~bllity of a flammable mlxture of

i vapor from reaching a property line. COMMITTEE ACTION: Accept.

Change " in l t ia l " to "maximum" In second line of proposed 2121(d). COMMITTEE COMMENT: Commlttee had considered "~nitial" as being '~maximum" but agrees that "maximum" better states the intent.

~9A-21 - (2121(e)): Reject SUBMITTER: Lester V. Heben~treit, Kidde Belleville, A Divislon ~ K i d d e & Co. RECOMMENDATION: Revise paragraph to read " . . . - e.g. impounding surface insulation, water curtains, high expansion foam systems - may be . . . . . " SUBSTANTIATION: High expanslon foam systems have been tested and found to be greatly effective in mtigatlng the vapor hazard. Several systems have been, and are being, designed for this function as well as for flame radiation control, and therefore, this method must not be excluded from the l is t , COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment 23.

t

5gA-23 - (Chapter 2, Paragraph 2121(e)): Accept SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas ~ o n of America RECOMMENDATION: Proposed:

The phrase " . . . - -e .g . , impoundlng surface insulation or water curtains-- . . . "

Recommended Change: " . . . - -e .g. , impounding surface insulatlon, water curtains,

etc.-- . . . " SUBSTANTIATION: The change includes but does not l imit the ~hods to the examples. COMMITTEE ACTION: Accept intent.

mend 2121(e) (TGR Proposal 59A-9) in part to read "-e.g., impounding surface insulation, water curtalns, or other suitable methods-". COMMITTEE COMMENT: The Committee does not intend to l imit the m--~chods to those speciflcally clted. However, i t is not prepared to speciflcally acknowledge other methods at this time. I t is aiso the intent of this prowsTon to recognlze concurrent usage of all such suitable methods.

59A-24 - (222): Accept in principle SUBMITTER: Howard W. Patil lo, Air Products and Chemicals, Inc. ~ A T I O N : Add the following sentence: "Provlsions shall be made for the detection of flammable gases and vapors in buildings where their presence can create a hazard." SU_BSTANTIATION: I t wil l be d l f f icu l t , i f not impossible, in some cases to prevent the entry of flammable gases or~vapors into a building and provisions should be made to detect their presence so that personnel evacuation and other safety measures can be inltiated.

I COMMITTEE ACTION: Accept in prlnciple. --Add "(See 930)" to end of proposed 222. COMMITTEE COMMENT: Proposed 930 in TCR Proposal 59A-80 accomplishes Submitters' intent. Cross reference improves comprehension.

59A-2S - (Sectlon 26-New): Accept in prlnciple SUBMITTER: Max M. Levy, Columbia LNG Corporation ~ A T I O N : Revise 261, add 262, replace 263 and renumber as follows: 26. Concrete Materials 260 Concrete used for construction of LNG contalners shall be In accordance wTth Section 42. 261 Concrete structures that w111 be ~n normal, or perlodic contact wlth LNG shall be designed to withstand the design load, applicable envlronmental Ioadings and anticipated temperature effects. Such structures include but are not llmited to foundatlons for cryogenic equipment. They ~shall comply with the following:

(a) Design of the structures shall be in accordance with appropriate prowslons of 421.

(b) Materials and constructlon shall be in accordance with the appropriate provisions of 422. 262 Pipe supports shall comply with the requirements of Section 63. 263 All other concrete structures shall be investigated for the effect of potential contact wlth LNG. I f failure of these structures would create a hazardous condition or worsen an exlsting emergency condition, the structures must be suitably protected to min~mlze the effects of contact or they shall be made to comply with 261(a) and (b). 264 Concrete or incidental non-structural uses, such as slope protection and impoundlng area pawng, shall conform to ACT 304-73*. Reinforcement shall be a minimum of 0.5% of the cross-sectional area of concrete for crack control ~n accordance with Paragraph 2.7.2 of ACI-344". 265 Concrete whlch is not in constant exposure to LNG and whlch has been subjected to sudden and unexpected exposure to LNG, shall be inspected, and repaired i f necessary, as soon as practical after i t has returned to ambient temperature.

~ n d i x B for availabllity.

32

SUBSTANTIATION: As proposed the scope of this new section is too broad. I t requires that all concrete structures be deslqned and buil t to the specifications for concrete LNG containers." Where normal or periodic contact with LNG is planned, Section 42 should indeed be followed. I t should not be necessary to require that all concrete used in the terminal be subject to the requirements of Section 42.

In an effort to be conservative, the NFPA proposal even overrldes the requirements of Section 63 for pipe support design. Normal, 2500-3000 psi concrete wlth Grade 40 or 6Q • rebar (20,000 psi to 24,000 psi allowable stresses) will withstand LNG contact with only minor spalling or cracking occurring.

Columbia's rewording allows the designer the option of using an economical and safe design for appllcatlons where no detrimental effects will result from deterloratlon of the concrete. :OMMITTEE ACTION: Accept in principle.

Amend Section 26 (TCR Proposal 59A-14) as follows: I . Amend 261 by substituting "or" for the comma followlng

'normal" and by deleting "or potential" in the f i r s t sentence; ind by sub~tltutlng "for cryogenic equlpment." for ", pipe racks ~nd supportS." in the second sentence.

2. Add a new 262 as follows: !62. Pipe supports shall comply with Section 23.

3. Renund)er 262 in Proposal 59A-14 as 264. 4. Add a new 263 as follows:

263. All other concrete structures shall be investigated for the effects of potential contact with LNG. I f fai lure of these structures would create a hazardous condltlon or worsen an exlstlng emergency condition by exposure to LNG, the structures shall be sultably protected to mlnimlze the effects of such exposure or they shall comply with 261(a) or (b).

5. Renumber 263 in TCR Proposal 59A-14 as 265. COMMITTEE COMMENT: More correctly express the intent of the Committee.

59A-26 - (Chapter 2, Paragraph 261): Accept in principle SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas A s s ~ o n of Amerlca RECOMMENDATION: Proposed:

"Concrete structures that wil l be in normal, periodic or potential contact with LNG shall be . . ."

Recommended Change: "Concrete structures that wil l be in normal or perlodlc

contact with LNG or structures where potential exposure to LNG could worsen an emergency situation shall be . . ." SUBSTANTIATION: As proposed this section could require all concrete structures to be designed to the provisions of 421 and 422. COMMITTEE ACTION: Accept in principle. COMMITTEE COMMENT: See Comment 25.

5gA-27 - (4011): Accept in part SUBMITTER: Joel Anderson, Southern Energy Company ~ A T I O N : Revise as follows: 4011 Storage containers for LNG shall be designed for the minimum temperature of the LNG product to be stored when i t is at,atmospherlc pressure. Those parts ~f LNG storage containers which wil l normally be in contact with LNG and all materials used in contact with LNG or cold LNG vapor (vapor at a temperature below -50°F) shall be physically and chemically compatible with LNG and suitable for service at minus 168°C (minus 270°F). SUBSTANTIATION: This will c lar i fy the intent of the present wording and will also better define the term "cold vapor". Any possible exposure of the outer tank to damaging cold is covered under Section 4014 of this Chapter. COMMITTEE ACTION: Accept in part. 28Amend recommendation in TCR Proposal 59A-18 to read as follows:

Those parts of LNG coQtalners which will normally be in ontact with LNG and all materials used in contact with LNG or old LNG vapor (vapor at a temperature below minus 20°F (minus

.g°C) shall be physically . . . . " remainder unchanged except ~nterpose Fahrenheit and Celsius temperatures. ~OMMITTEE COMMENT: Clarification is consistent with Committee intent. However, the Committee feels that minus 20°F is more appropriate than minus 50°F to define cold vapor and conslstent with similar t~perature cri teria in the standard - e.g., Chapter 6.

59A-28 - (Chapter 4, Paragraph 4014): Accept in principle SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas ~ o n of America RECOMMENDATION: Proposed (by Committee):

" I f the outer surface area of an LNG container could be accidentally exposed to leakage of LNG or cold vapor from flanges, valves, seals or connections, this area shall be suitable for LNG temperatures or otherwise protected from the effects of such exposure."

Recon~nended Change: "Any portion of the outer surface area of an LNG contalner

that could be accidentally exposed to leakage of LNG or cold vapor from flanges, valves, seals or other non-welded connnections, shall be protected from the effects of such exposure." SUBSTANTIATION: The proposed revision is unclear as to specific intent. I t could be misinterpreted to require the protection of the entire outer tank. The proposed rewording more clearly states the intended requirements of this paragraph. COMMITTEE ACTION: Accept in principle. COMMITTEE COMMENT: See Comment 29.

,59A-29 - (4014-New): Accept SUBMITTER: Max M. Levy, Columbia LNG Corporatlon RECOMMENDATION: Revise as follows:

I ny portion of the outer surface area of an LNG container that ould be accldently exposed to low temperatures resulting from eakage of LNG or cold vapor from flanges, valves, seals, or ther non-welded connections, shall be suitable for such emperatures or otherwise protected from the effects of such xposure.

SUBSTANTIATION: The proposed revision is unclear as to specific intent. I t could be misinterpreted to requlre the protection of the entire outer tank. The proposed rewording more clearly states the ]ntended requirements of this paragraph.

I COMMITTEE ACTION: Accept.

Amend recommendation in TCR Proposal 59A-20 to read as proposed by Submltter. C~ITTEE COMI~ENT: Amendment better reflects intent of Committee.

59A-30 - (4014): Reject SUBMITTER: E. C. Sommer, Exxon Research & Engineering Co. ~ A T I O N : Delete the words "or connections" from this new proposed paragraph. SUBSTANTIATION: Unless "connection" is more fu l ly described, i t could be interpreted to mean the main pipe, for example, from a manifold into a roof mounted pump. This is a connection. COMMITTEE ACTION: Reject. COMMITTEE COIq~ENT: Committee feels that 4014 should include all non-welded connections. See Comments 29 and 28.

59A-31 - (402-Existlhg 406): Reject SUBMITTER: Max M. Levy, Columbia LNG Corporation ~ A T I O N : Revise as fol lows: 402 Seismic Design.

Delete ent i re section from paragraph 4020 through 4026. Revise to read: 402. Seismic Design. 4020. Selsmlc loads shall be considered in the design. 4021. For fac i l l t les described in (a) and (b) of this paragraph, the operator shall conduct a detailed geotechnlcal investigation and determine proximity to faults, the seismic response spectra, potentlal for motion ampllf~cation, potential for soll liquefaction, and potential for surface rupture:

(a) A f ac i l i t y which is located in Zone 2, 3, or Zone 4 of the "Seismic Risk Map of the United States," UBC, or in Puerto Rico, not including a fac i l i t y with total LNG storage capacity provided by one or more horizontal cylindrical or double wall metal storage tanks of less than 100,000 gallon capacity each, mounted within 2 feet of the ground.

(b) A fac i l i t y located where there is evidence indicating a potential for sqrface faulting. 4022. For all fac i l i t ies not described In 4021, the following structures and systems shall be designed and bui l t to withstand the forces listed in (a) and (b): (1) an LNG container and Its impounding system; (2) system components required to isolate the LNG container and malntaln i t in a safe shutdown condition.

(a) The horizontal seismlc acceleration and other applicable factors set forth in the UBC, Volume I , corresponding to the zone of the "Seismic Risk Map of the United States" in which the fac i l i t y is located.

(b) A vertical seismic acceleration equal to 2/3 of the horizontal acceleration and the associated applicable factors. 4023. In the case of LNG fac i l i t ies llsted in 4021, the cr i t ical components set forth below must be designed and bui l t to withstand the most cr i t ical maximun~ horizontal and vertical response spectra (with respect to the natural period of the structure) determined to have occurred at the site as a result of an earthquake or determined to have the following probability of not being exceeded at the site in 50 years, whichever is larger, considering motion am~)llcatlo n and symmetric and asymmetric reaction forces resulting from hydrodynamic pressure and motion of contalned liquid in interaction with the component structure:

33

Critical Component

Storage tanks and their ~mpounding systems . . . . . . . . . . . . .

Transfer plping, shutdown control systems, other flammable liquid containers . . . . . . . . . . .

Probabillty of Response Spectra Not

.... Being Exceeded

99.5%

90.0%

4024. Each container which does not have a structurally, sound, liquid-tight cover, must have sufficient freeboard with an appropriate configuration to prevent the escape of liquid due to sloshing, wave action, and vertical liquid displacement caused by seismic motion. 4025. Shop-built contamers designed and constructed in accOr4ance with the ASME Code (see definition), and their support system, shall be designed for the horizontal and vertical seismic accelerations in Table 4-1. Zones shall be determined from Figure 4-I.

Zone

0 1 2 3

Table 4-1

Design Earthquake %G

2 7

15 28

4 As determlned by in- vestlgation in accordance with 4021.

SUBSTANTIATION: I t is recommended that the baslc rewording

~ roposed by Materials Transportation Bureau DOT in their Notice of roposed Rulemaking - 49, CFR Part 193 be used. This document

recognizes the varying levels of rlsk associated with pla~t locations and their proximity to different seismically active areas. Part 193 appears to be a safe, sensible and economi§ approach to the question of seismic investigation and design. NFPA's proposed revision, however, is an unnecessary and excessive shift toward str ict nuclear plant type regulations, design crl teria (OBE & SSE) and termlnology.

Seismic investigat~on and deslgn technlques have advanced greatly in the last decade. Arbitrari ly requiring the use of these techniques, regardless of area seismicity, is a costly misuse of the state of the art. This only serves to reinforce the mistaken concept that LNG faci I i t les should be equated wlth . nuclear fac i l i t ies. As worded Jin Part 193, the consequence of failure at both types of plants is recognized ~nd the design requirements are ~hus more wisely balanced in relation 'to seismic probabiIitles.

The NFPA proposed amendment relies heavily on the SeismicZone Map of the Applled Technology Council Project ATC-3, which has not yet been published, and advanced selsmic design techniques such as TID-7024.

At present the ATC-3 informatlon has not been published and is not available to the general public. Therefore, the Seismic Risk Map of the United States published by the Environmental Science Servlce Admlnlstration should continue to be referenced slnce i t remains a slgn~ficant means of evaluating seismic actlvity. I t is reasonably well held that for some conditions and particularly In low seismically active areas the 1976 Uniform Building Code techniques are comparable to some of the better known design methods such as TID-7024 or equivalent foreign standards. Th~s latest edition (1976) includes a soil-structure interaction factor

lwhich even in areas of low seismic activity wil l require some seismic response spectrum and soil characteristlc investlgation, thus attaining the sought after improved seismic deslgn.

I OMMITTEE ACTION: Reject specific recommendation. Amend Table 4z1 by deleting "SSE," from the headlng of the econd column.

COMMITTEE COMMENT: The Submltter's proposal for 4021 neglects many important parameters cr i t lcal to a seismic evaluation whith are included in the TCR Proposal 59A-21. For example, the Submltter's proposal would Iimlt the requirement for an ~nvestigation to Zones 2, 3 and 4 of the UBC Map. The Commlttee beli6ves that the selsmlc evaluation should be performed on a consistent basis for the e~tlre nation. The investigation required will assure that each individual site is investlgated for sultabi l i ty rather than relying upOn general survey data judged typical for a large .area. In addition, the proper investigation wil l provide the necessary assurance to the public regarding the safety and re l iabi l i ty of the fac i l i ty .

The Submltter's proposed 4022 cites UBC design cri terla for faci l i t ies not listed in 4021. The Commlttee has been advised th'at the 1979 edition of the UBC will .not cover aboveground liquid storage tanks. The Submltter's 4022(a) references the UBC "Selsmlc Risk Map of the United States." The Committee's proposed use of the Applled Technology Council Map is more up-to-date, better reflects the seismlc rlsk and Is available to the public through the National Bureau of Standards as referenced in Appendix B. The Committee also believes that the geotechnlcal invest~gatlon'will determine the appropriate vertical seismic acceleration. •

Submitters' proposed 4023 fai ls to define the appropriate stress level for the OBE and SSE earthquakes andlcould lead to misapplication and gross over or under design. Paragraph 4024 in TCR Proposal 59A-21 defines the stress limit philosophies to be used for design purposes and thus completes the unified approach sought by the Committee. The 90% probability of exceedance proposed by the Submitter is addressed by the Committee Action on Comment 35.

Paragraph 4025 in TCR Proposal 59A-21 adds the necessary clarif ication for tank design regarding the dynamic effects of seismic events in a more suitable fashion than does the Submitter's proposed 4024.

The Committee agrees that Table 4-1 should be amended by deleting "SSE", from the heading of the second column.

59A-32 - (4020, 4022, 4023, 4024, 601): Reject SUBMITTER: Richard Scholz, Consolidated Edison Co. of New York, Inc. RECOMMENDATION: Amend as follows: 4020 Seismic loads shall be considered in the design of an LNG Facility. For installations in moderate to high risk a~eas such as zone 2, 3, and 4 of the "Seismic Risk Map of the Unlted States", as published in the UBC, investigation shall be conducted to obtain pertinent geotechnical information concerning the geologic and selsm~c characteristics of the LNG fac i l i t y and the surrounding region, i 4021 Leave as Proposed. 4022 Rewr~te Section 4022 and replace with wording similar to what is In the proposed DOT part 193:

The fac i l i t y shall be designed to withstand the "horizontal and vertical response spectra determine to have occurred at the site or Which potentially could occur at the site with a probability of not being exceeded for 50 years". 4023 and 4024 These Sections are not needed and should be'delete~ i f comments are adopted. 601 Delete last two sentences not needed when other comments are incorporated. SUBSTANTIATION: To require that all operators perform "an investigation--to determine the seismic potential and resulting response spectra" Is too restrictive and provides no useful purpose In areas with historically small/earthquake actl'vity. Areas such as New York City have a relatively long history of recorded earthquake activity, Which is not to say tha t earthquakes are not possible, but rather than those that do occuh are no danger to code designed.structures.

In fact, safety factors required by buildlng codes and used in the design of structures such as for wind loading would be adequate to sustain minor vibrations. Even i f we should postulate an incredible earthquake which would demolish New York City would i t be rational to design an LNG plant to sustain such an earthquake?

The proposed w~rding parallels the nuclear plant siting criteria as well as the California design criteria but both of these cri teria cannot be the basis for LNG plant siting nor are they applicable to all other areas of our country. Obviously.nuclear pl@nts have inherently much greater rlsk to l i fe than LNG plants. Release of radioactive material can cover large areas and such contaminated areas would stay this way for many years; wh~le LNG spillslare contained withln small areas and i f ignited would burn out in a matter of days. In many other regions earthquakes are only minor tremor~ and seismic analysis is not used in these areas because i t has been evident that structures inherently can withstand loads imposed by these small earthquakes. Even the present issue of the proposed DOT takes thls into account. COMMITTEE ACTION: Reject. coMMITTEE COMMENT: See Comment 31.

59A-33 - (4021(a)): Accept SUBMITTER: B. H. Bakerjian, public Service Electric and Gas Company IRECOMMENDATION: Change the word "for" between the words i"appropriate" and "the" to "at". SUBSTANTIATION: I t could be interpreted as wrltten that the Tnvestlgatlon of surface faultlng extends for some indefinlte distance around the speciflc site. The word change makes i t clear that the investigation 1's for the site only. ICOMMITTEE ACTION: Accept. COMMITTE E COMMENT: Agrees with Commlttee intent. .

i

59A-34 - (Chapter 4, Paragraph 4022)): Accept in part SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas Association ~ a RECOMMENDATION: Proposed: Paragraph 4022 should be deleted. .... S ubstl~ute: "4022. The investigation shall determine the design ~arthquake which shall be deflned as follows: t

34

The design earthquake shall be defined as (1) the earthquake which would produce the maximum ground motion at the site based on deterministic procedures considering reglonal seismic potential, local and regional geology and seismology, and subsurface conditions; or (2) the earthquake which, based on a probabillstic evaluation, has a mean recurrence interval of 10,000 years." SUBSTANTIATION: The proposed revision to this section on Seismic Deslgn requires that the geotechnlcal investigation shall determine the design earthquake. The deslgn earthquake is generally considered to be the earthquake which would produce maximum vibratory ground motlon at the site.

This currently proposed section defines the SSE and OBE in terms of recurrence levels, the SSE having a mean recurrence interval of 10,000 years and the OBE having a 1,000 year mean recurrence interval. The specif~catlon of these design events in terms of recurrence levels is objectionable for two reasons, these being ( I ) the use of recurrence levels as a deflnltion requires a probabilistic evaluation and (2) the specified recurrence levels are somewhat arbitrary values.

The use of an OBE cr i ter ia has been ehm~nated. The speciflcatlon of an OBE is a requirement beyond the scope of this standard. By designing the fac i l i t y to the maximum deslgn earthquake (SSE as proposed), NFPA is assuring the safety of the public. The fac i l i t y wil l also remain safe i f subjected to a lesser level event and any adverse effects will not affect public safety but may be economic in nature. The operator should be allowed to determine the event to which a structure remains elastic based on the economic consequence should that event be exceeded.

The use of the probabilistic approach in the determination of design events in some areas of the country is highly suspect due to the limitations of the methodology for such an applidatlon. The probabllistic evaluation attemgts to predict events with the extreme mean recurrence intervals of up to I0,000 years by means of mathematical formulations while based on a data base of several hundred years. Many professlonals in the earthquake f le ld believe the extrapolation of the limited data to such extreme probabilities is fundamentally unsound. The probabillstic approach also relies on input which at this time is subject to debate within the profession and requires more research and evaluation, such as recurrence relations, attenuation laws, and area selsmicity ~nterpretation. Consequently, as a result of the use of input parameters whose exact values are d i f f i cu l t to evaluate, the output recurrence or probabilities can vary by orders of magnitude. I t is not inconceivable for three coe~)etent seismic investigators to arrive at three considerably different design earthquakes with a recurrence interval of 10,000 years. Thus, i t must be acknowledged that the probabilistic approach has significant limitations which may preclude its use for the determination of the design earthquake, mainly:

I . The procedure may lack a sufficient ~tatistlcal data base. 2. The model may not represent the physical mechanicms

accurately. 3. The mathematical procedure is c ~ l e x , and one may lose

touch with the physical 11mitations of the problem and ar t l f l ca l l y attempt to extract mure information then exists in the source material.

The requirements of )0 CFR 100 Appendix A regulations for seismic cr l ter ia 'o f nuclear power plants, are stated in a general manner and the level of the design earthquake is deflned to be established by deterministic procedures. In many parts of the country, the determlnl~tic procedure Is preferable over a probabilistlc approach because heavy emphasis is placed on regional and local geology, tectonics and se~smicity, because the end result is dependent on the quality rather than the quantity of the data, and because of the aforementioned limitations of the probabilistlc approach.

In st~ary, the probabilistic approach has severe limitations in many parts of the country, and should not be used for determining the design earthquake which should be evaluated by deterministic methods as is current practice. While probabilistic procedures may be useful in determining less extreme events, the limitations of such analyses must be recognized. Although much effort is being devoted to the probabllistic approach, the state of the art is not sufficient to warrant its establishment as a sole basis for determining a design criterion. Total changes in philosophy as a result of as yet unverifiew:[ advances in the state of the art may be imprudent and may not be in the best interest of the industry and the public, Accordingly, the probabilistic method should be applicable only for areas where sufficient data base just i f ies its ia~)lementatlon, Differences in regional geology require that an allowance must be made in order to determine the applicable procedure for each site. C(W(MII'FEE ACTION: Accept in Part. See Comment 35.

59A-35 - (4022): Accept in principle SUBMITTER: Patrick J. Hester, Algonquin Gas Transmlsslon Company ~ A T I O N : The investlgation shall determine the Safe Shutdown Earthquake (SSE) and Operating Basls Earthquake (OBE) which shall be deflned (a) probabilistlcally, as those which produce ground motions with a mean recurrence Interval of i0,000 years for the SSE and 475 years for the OBE; or (b) determlmstically, where the SSE is the event which produces the maximum credible ground motion at the site based on the seismology, geology, seismic and geologlc hlstory of the slte and the region, and where the ground motions for the OBE shall be one-half those determined for the SSE. SUBSTANTIATION: Whlle i t is recognized that the state of the art in seismic design and earthquake engineering has developed

' " d considerably slnce 1975, i t has not advance to where the ut i l izat ion of probabilistic cr i ter ia as regulatory standards are warranted. The determination of the design ground motlgns should not be solely based on absolute values calculated by probab11istic methods. Many parts of the country lack the selsmlc data base mandatory to accurately perform such an analysls to the extreme probabllltles speclfled in the text. Additionally, such an analysis involves the use of several parameters such as attenuation laws and recurrence relations whose exact values are d l f f l cu l t to evaluate in many geographic regions. Extrapolating a data base of 200-300 years to the extreme recurrence intervals of 10,000 years is mathematlcally questlonable. The application of such a procedure to many parts of the country will yield results which are unreallstically hlgh and unjustifiably overconservative. The uncertainties involved in determining the tai l of the distribution function at these extreme probabilities is the subject of great debate. Consequently, in those parts of the country where a probabillsltlc approach isn' t justlf~ed the operator must be allowed the f l e x i b i l i t y to ut i l lze an alternate method which wil l produce acceptable and physlcally credible results. This alternative is the deterministic approach which is used extensively in the determination of design events in the nuclear industry.

The 1000 year recurrence mterval of the OBE as determined by probab~listlc procedures is arbl t rar l ly high. This corresponds to a probability of not being exceeded of 95% in 50 years which is extreme for an operating basis event. An UBE is generally conceived as that event which has a reasonable chance of occurring at the slte durlng the operating l l fe of the plant. I t is generally an economic threshold over which the operator wil l suffer financial consequences should be event be exceeded. In a paper presented in the July 197B Journal of the Geotechnlcal Engineering Division of ASCE Christian, et al. noted that the NRC staff recently indicated "that a reasonable probabilistlc description of an OBE is that i t have a return period of at least llQ years and have a probability of exceedance of no more than 30% during the plant l i fe " . In that paper the authors also recommended an UBE return period of 10 times the plant l l fe . The proposed 475 year return period is equivalent to a probability of not being exceeded of 90% in 50 years whlch is the cri teria to which the recent ATC-3 seismic zonlng maps were formulated. Anticipating the adoption of the ATC-3 maps by the UBC, this 475 year period represents an adequate and safe level of seismic design for which the str~cture is to remain elastic. The OBE is an arbitrary lim}t from a safety viewpoint because the structure must s t i l l withstand the mere severe SSE without collapse or catastrophic failure. Accordingly, the OBE should not be as r~ote an event as currently proposed in the Technical Committee Report. A 475 year return period for the OBE is considered a more rational approach. The corresponding OBE evaluated by a deterministic approach is suggested as being one-half of the SSE. This is an approach uti l ized by the nuclear industry in lieu of a detailed probabillstic and cost-benefit evaluation of the QBE. :OMMITTEE ACTION: Accept in prlnciple.

Amend 4022 as recommended in TCR Proposal 5gA-21 by substltutlog the following after the word "deflned":

"(a) probabil lstically, as those which produce ground motions iwlth a mean recurrence interval of 10,000 years for the SSE and 475 years for the OBE, or (b) in regions where the uncertainties are d i f f i cu l t to quantify because of the lack of geologlcal data, the determlnistlc approach shall be used where the SSE is the event which produces the maximum credible ground motion at the islte based upon the seismology, geology, seismic and geologic history of the site and region, and where the ground motions for the OBE shall be one-half those determined for the SSE. COMMITTEE COMMENT: The Committee belleves that a probabillstlc approach is most appropriate when there is a sufflc~ent data base. However, i t recognizes that there are regions where such a data base simply is not available.

f

5gA-36 - (Chapter 4, Paragraph 4024): Reject SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas Association

Amerlca RECOMMENDATION: Proposed:

An LNG container shall be designed for the OBE and a stress l imit check made for the SSE. Stresses for the OBE shall be in accordance with the code or standard applicable to the container as specified in this standard. Stress l~mlts for the SSE shall be allowed to reach yield for the tensile condition and cri t ical for the buckling condition when including the effect of liquld pressure on buckling stabi l i ty .

3S

(a) After an SSE event, the container shall be emptied and inspected prior to resumption of container f i l l i ng operation.

Recommended Change: An LNG container shall be designed for the design earthquake.

Stress limits for the design earthquake shall be allowed to reach yield for the ~ensile condition and cri t ical for the buckling cond~tlon when including the effect of l~quid pressure on buckling stabi l l ty . Afte~ a design earthquake, the container shall be emptied and ~nspected prior to resumptmn of container f~l l ing operations. SUBSTANTIATION: To remain consistent with previous comments on paragraph 4022. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Committee believes that 4024 should remain as recommended to ~ f l ec t the concern that re l iab i l i t y and survivabil i ty of a tank must be evaluated. Prudent engineering calculations are needed - e.g., OBE - in which Code allowed stresses are uti l ized.

59A-37 - (411~(c) - existing 4122(c)): Accept SUBMITTER: B. H. Bakerjlan, Public Service Electric and Gas ~ p a n y ~ I O N : Change the word "out" between the words "and" and |"contalner" to "outer". SUBSTANTIATION: Does not read properly.

~COMMITTEE ACTION: Accept. Amend as recommended by Submltter.

59A-38 - (4112(g)): Hold for further study SUBMITTER: Melvyn Blake and E. Bruce Belson, Avco Specialty ~ D i v i s l o n RECOMMENDATION: The proposed paragraph appears to be somewhat ambiguous, does not address at least key requirements of service in an LNG fac i l l t y , and presents a requirement which is not l lkely to exist In an LNG fac i l l t y . I f the intent of paragraph 4112(g) is to 1) specify{hat foundations and'supports have a f i re protectlon coatlng or coverlng and 2) define the requirements of that coating or coverlng, then I suggest the following:

"Foundatlons and supports shall be fireproofed w~th a material capable qf providing one hour protection in a hydrocarbon f l re environment. On structures exposed to the elements, the flreproofing coating or coverlng shall be deemed sultable for exterior use servlce by a nationally-~ecognized testing laboratory. Exposure to cryogenic environments shall not cause degradation of the f i re protection characteristlcs of the coating or coverlng. Further, i t shall be resistant to dlslodgement by f l re hose streams under the following conditions.

(In thls subparagraph, the Committee should deflne realistic hose stream conditmns which might occur In an LNG fac i l~y , based on its members knowledge of real l l fe conditions.)"

I f the intentlon of paragraph 4112(g) is ~o define requirements of a f i re protection system other than a coating or covering, then that other system should be defined.

I f the Commlttee ~s unwilling or unable to specify all relevant requirements because of tlme l~mitations, then ~t mlght be approprlate to delay inclusion of proposed paragraph 4112(g) to the next edition of Standard No. 59A. SUBSTANTIATION: a.) When the term "two hour f i re protection" ~s specified, ] t usually refers to the ASTM E-119 f i re test. While th~s t6st may have relevance to the type of f~re which can occur in resldentlal, commercial, and certain industrial structures, ] t has no relationship to the type of f i re which could occur ~n an LNG fac i l i t y . The ASTM E-119 f~re~is characterized by a l imted fuel supply, limited oxygen supply, and a slow rise in temperature. In an LNG fac i l i t y , when a leak, sp111, or gas l~ne rupture would occur, followed by ignition, fuel and oxygen supply would be essentially unlimited, and temperature would rlse to 1800°F to 2000:F in a very ~ew mlnutes--in short, a h~gh intensity f~re. The attached Warren and Corona paper has already proven that some materials capable of providing three hours protection ~n an ASTM E-119 f l re test w111 only prowde one hour protection ~n a hydrocarbon f i re . Therefore, f i re protection ~n a hydrocarbon environment should be the means of defining f i re protection in an LNG fac i l i t y .

Unfortunately, there ~s no natlonally-recogn~zed test standard for hydrocarbon f~re protection. However, some third parties have conducted such tests; and until ASTM establishes a high intensity f l re test, third party reference could be used.

b.) I t is necessary that a f~re protection coating or covering w~thstand exterior exposure i f ~t will ~n fact be used to protect foundations and supports exposed to the elements.

c.) Concelvably, foundations and supports can be exposed to LNG. Unless a f~re protectlon coating or covering ~s able to stay in place when exposed to cryogenic l iquid, i t IS of questlonable value ~n an LNG fac i l i t y .

I am aware of one LNG fac~llty where evaluation of hose stream resistance is determined with a garden hose - other fac i l i t ies require more realistic test conditions. To remove any questions, and so that a standard exists, hose stream cond~tlons should be defined.

COMMITTEE ACTION: Hold for further study. COMMITTEE COMMENT: Recommended material introduces concepts which have not had public review. However, Committee does not agree that its recommended 4112(g) should be withdrawn pending completion of such a study. Proposal is not restricted to use of' insulation, per se. Neither is i t specific as to type of insulation. Whlle i t is agreed that i t would be desirable to establish more complete cr i ter la, the Committee feels that the character of LN8 fac111ties warrants appl icat ion of engineering expert ise that can solve th ls problem in a s l te -spec i f i c way.

F

59A-39 - (4113): Accept SUBMITTER: Howard W. Patt i l lo, Air Products and Chemlcals, Inc. ~ A T I O N : The designatlon "inner tank" and 'hnner container" seems to be used interchangeably. Chapter 4 should be rewewed for censlstency. SUBSTANTIATION> Deslgnatlon of LNG storage container parts or systems should be conslstent throughout to eliminate any possibil i ty of misinterpretation of requirements. COMMITTEE ACTION: Accept. COMMITTEE COMMENT: Entire standard wil l be revlsed to reflect this editorial matter.

59A-40 - (4212-existing 4222): Accept SUBMITTER: B. H. Bakerjlan, Public Service Electric and Gas Company

IRECOMMENDATION: Delete the word "conditlons" between the word r'conditions"and "shall". SUBSTANTIATION: Delete repetition of word.

ICOMMITTEE ACTION: Accept editorial correction.

59A-41 - (4720): Accept SUBMITTER: E. C. Sommer, Exxon Research & Englneerlng Co. I ~ A T I O N : Change second sentence to read: "This stop valve l(or valves) shall be lockable or sealable in the ful l open Iposltlon." I Also add new sentence,

"When only one re l lef devlce is required, a fu l l port openlng Ithree-way valve may be used for the rel ief device and its required Ispare in lleu of indlvidual valves beneath each rel ief device." SUBSTANTIATION: The words, "When an indivldual safety rel ief valve,'~ have no apparent meaning. Also the proposed new sentence recognizes the use of a three-way valve which is quite common practice. COMMITTEE ACTION: Accept.

Amend TCR P-~osal 5gA-44 as proposed by Submitter except change l"for" to "under" in recommended new last sentence. COMMITTEE COMMENT: Consistent with CommTttee intent.

59A-42 - (4720-New): Accept ~n pr inc ip le SUBMITTER: B. H. Bakerj ian, Public Servlce E lec t r ic and Gas

RECOMMENDATION: In the second f u l l sentence of the Recommendation, change the word "when" to "wl th" and the word " th is " to " the" . , SUBSTANTIATION: The sentence does not read properly. I t is assumed that the recommended changes do not modify the in tent . COMMITTEE ACTION: Accept in pr lnc lp le . See Comment 41.

59A-43 - (4720): Accept in principle SUBMITTER: Joel Anderson, Southern Energy Company RECOMMENDATION: Revlse as follows:

pressure and vacuum safety valve for LNG containers shall be able to be isolated from the container for malntenance or other purposes by meads of a manual fu l l openlng stop valve. Each stop valve shall be lockable or sealable In the fu l l open position. Sufflclent pressure and vacuum tel ler valves shall be installed on the LNG contalner to allow each rel lef valve to be indlvidually isolated for testing or maintenance while malntalning the fu l l capacTt]es determlned in paragraph 472. ' SUBSTANTIATION: In the present wording, the f l r s t sentence makes havlng stop valves mandatory. The second sent~nce makes this mandatory requlrement sound as i f i t is optional. The recommended change will c lar i fy the intent. COMMITTEE ACTION: Accept in prlnciple. See Comment 41.

5gA-44 - (473-New): Reject SUBMITTER: Max M. Levy, Columbla LNG Corporatlon ~ A T I O N : Safety re l lef valve dlscharge stacks or vents shall be designed and installed to prevent an accumulatlon of water, ice, snow, or other forelgn matter and, i f arranged to dlscharge dlrectly into the atmosphere, shall discharge vert lcal ly or horizontally away from the tank.

36

SUBSTANTIATION: Design for horizontal discharge away from the tank can be an equally effective means of protecting the tank from cold vapor exposure wh~le preventing accumulations of water, ice, snow or other foreign matter that could jeopardize the operation of the rel ief valve. COMMITTEE ACTION: Reject. COMMITTEE COf4WENT: Vertical discharge provides additional protection against thermal radiation from an ignited discharge and reduces the probability of cold vapor being drawn down the leeward side of a tank.

5gA-45 - (4/3-New): Accept SUBMITTER: B. H. Bakerjlan, Public Service Electric and Gas ~ompany

I RECONMENDATION: Add the word "upwards" to the end of the sentence. SUBSTANTIATION: I t would not be desirable from a safety point of view to have a safety valve discharge pointed downwards.

I OMMITTEE ACTION: Accept. OMMITTEE COMMENT: Amend TCR Proposal 5gA-45 as recommended by ubmitter.

5gA-46 - (601): Accept in principle SUBMITTER: Howard W. Patil lo, Air Products and Chemicals, Inc. ~ A T I O N : Delete f i r s t sentence of paragraph. SUI3STANTIATION: The second sentence requires results of a seismic study to be applied to the piping design. This seems to eliminate the need to determine i f seismic loads are appllcable.

I COM~.ITTEE ACTION: Accept in principle. Delete "When applicable", from proposed f i r s t sentence,

COMI41TTEE COMMENT: Acc(wnplishes intent of both Submltter and ~oavnYttee while leaving rest of f i r s t sentence for better overall context. \

COMMITTEE ACTION: Accept. I~ I . R ep'iace existing f i r s t sentence with sentence proposed as third sentence.

2. Amend existing second sentence to read "Particular onslderatlon shall be given where changes . . . . " remainder nchanged except make "occurs" slngular.

COMMITTEE COMMENT: Additional changes improve clar i ty.

59A-50 - (6101-New): Hold for future study SUBMITTER: E. C. S o ~ r , Exxon Research & Engineering Co. R~'L'OIqRi~'I~]ATION: Delete, "or the heat of an ignited sp i l l , " In the f i r s t sentence. Also add new sentence; "Unless the piping can be isolated to stop flow when exposed to the heat of an ignited spi l l , the piping shall be protected by insulation or other means to delay failure until corrective action can be taken. SUBSTANTIATION: Any ignited spil l could cause piping failure and any failure could significantly increase the emergency. Thus, essentially all piping would have to be protected against f i re exposure. The suggested wording would provide some rel ief . Br i t t le failure due to low temperature could be instantaneous but f i re exposure involves a tlme element which can be handled by isolation valv~ng. CONMITTEE ACTION: Hold for future study. COMMITT~ COI4~ENT: Reco~ndation introduces new concept which has not had publlc review.

5gA-51 * (6102-New): Accept SUBMITTER: B. H. Bakerjian, Public Service Electric and Gas ~-~ompany

I RECONMENDATION: Delete the word "shall" between the words "areas" and "where". SUBSTANTIATION: As written, the sentence does not read properly.

~ O N : Accept editorial correction.

59A-47 - (601): Accept In part SUBMITTER: Max M. Levy, Columbia LNG Corporation ~ A T I O N : Revise 601 as follows:

When appllcable, seismic loads shall be considered in the piping design. Results of the seismic study of 402, or the accelerations in Table 4-I as applicable, shall be used to determine the forces that would be applicable to the piping design. The longitudinal stresses, which are developed in this analysis, shall meet the requirements of 302.3.6(a) of ANSl B31.3. SUBSTANTIATION: NFPA's proposed amend~nt is an unnecessary and excessive shift toward str ict nuclear plant type design cr i ter ia and terminology. Use of Operating Basis Earthquakes and Safe Shutdown Earthquakes have no application in an LNG terminal and only serve to reinforce the mistaken concept that LNG fac i l i t ies should be equated with nuclear fac i l i t ies .

As modified, paragraph 601 better reflects the philosophy of the Materials Transportation Bureau DOT in their Notice of Proposed Rulemaking - 49 CFR Part 193. Part 193 recognizes the varying levels o~risk associated with LNG versus nuclear plants and more wisely juUges the consequences of failures.

I OMMITTEE ACTION: Accept in part. Delete next to the last sentence in TCR Proposal 59A-47. Amend

ast sentence in Proposal by substituting "meet the provisions of 023(b)." for "remain functional after a safe shutdown earthquake

~(~TEE COMMENT: The former next to the last sentence is redundant to the preceding sentence which states design c r i t e r i a in more understandable manner. Amendment of the last sentence better defines the functional requirements. See Comment 46 for fur ther amendment of this Proposal.

59A-48 - (601): Accept SUBMITTER: B. H. Bakerjlan, Public Service Electric and Gas ~'--ompany RECOMMENDATION: Delete the following sentence:

"All piping systems shall be designed to safely resist the- effects of an Operating Basis Earthquake (UBE) and remain functional afterwards." SUBSTANTIATION: The paragraph starts out with the judg~ntal phrase, "When applicable . . . . ." To follow this with a requirement is inconsistent. Additionally i t is not fe l t necessary from a safety point of view that all piping systems must be analyzed for the dynamic response called for. COMMITTEE ACTION: Accept. See Comments 47 and 46.

59A°4g - {602): Accept SUBMITTER: Howard W. Pati l lo, Air Products and Chemicals, Inc. ~ A T I O N : Delete f i r s t sentence of paragraph. SUBSTANTIATION: The addition of the last sentence negates the need for the f i r s t sentence. Consideration of frequent temperature changes and affects of thermal cycling are interpreted to be the same.

59A-52 - (6221): Reject SUBMITTER: Howard W. Pati l lo, Air Products and Chemicals, Inc. ~ A T I O N : New Sentence: Change wording from "designed LNG liquid level" to "maximum LNG liquid level." SUBSTANTIATION: Valves should be located as specified on al l penetrations below maximum LNG level. I t is believed the wording "designed LNG liquid level" could be interpreted at a point lower than maximum level. COMMITTEE ACTION: Reject. CO~IMITTEE CO~Q4ENT: There is no generally accepted definition of ~maximum liquid level." "Designed liquid level" is an accepted term used by the design engineer for applications covered by this standard.

5gA-53 - (6221): Accept In part SUBMITTER: Max M. Levy, Columbia LN(; Corporation ]I~'-C-(~@iiIE'NI~ATION: Delete proposed amendment, SUBSTANTIATION: The proposed revision is poorly conceived. In two situations, i t is v i r tua l ly impossible to acconqolish these requirements in a double well tank with an aluminum inner she11. These situations are:

1) A flanged stainless valve would be required to act as the aluminum to stalnless transition Joint. I f a flange Joint is unacceptable at this location, the alternative would be a weld-end aluminum valve, which is also unacceptable.

2) In the situation where a bottom floor penetration withdrawal/fil l line is used the valve would be required under the inner tank and I t would therefore also be inside the outer tank. I t should be stressed that an internal shutoff valve is used in many instances to attain the safety levels being sought in a much more acceptable manner.

I CONMITTEE ACTION: Accept in part.

Delete reco~mnended new last sentence in TCR Proposal 5gA-53. Add "and shall be located inside the impounding area" to the end of the last sentence of existing 6221. COMMITTEE CONMENT: Committee agrees that its proposal was impractical to the extent noted.

SgA-54 - (6221): Accept in part SUSMITTER: Joel Anderson, Southern Energy Company ~ A T I O N : Revise as fol lows: 6221. Shutoff valves shall be provided on container, tank and vessel connections, except connections:

(a) For r e l i e f valves (shutof f valves are only permitted at connections for r e l i e f valves in accordance with Section V I I I , Division 1, of the ASME Code, Paragraphs UG-125(e) and Appendix M, UA-354, and UA-355.

(b) For l iquid level alarm required by 7001. (c) That are blind flanged or plugged. Shutoff valves shall be located as close as pract icable to such

containers, tanks, and vessels. LNG container shutoff valves fo r ~ lping penetrations of the container below the designed LNG l iquid eve] shall be located inside the impounding area.

37

SUBSTANTIATION: The requirement to locate the external shutoff valve at the f~rst c~rcumferential weld ~s unnecessary assuming that acceptable welding procedures are followed on all welds between the tank and the external shut-off valves. COMMITTEE ACTION: Accept in part. See Comment 53.

59A-55 - (6221): Reject SUBMITTER: B. H. Bakerjian, Public Service Electric and Gas Company RECOMMENDATION: Add the word "pipe" between the words "circumferential" and "weld". SUBSTANTIATION: As written ~t Is not clear what the c~rcumferential weld is associated with. I assume i t is a pipe. The reference to "pipe" avolds maklng an assumption. COMMITTEE ACTION: Reject: COMMITTEE COMMENT: Inapplicable in view of Committee Action on Comments 53 andS4.

59A-56 - (6221(a)): Reject SUBMITTER: Howard W. Pat~llo, Air Products and Chemcals, Inc. RECOMMENDATION: Add reference to Paragraph 4720. SUBSTANTIATION: Paragraph 4720 requires shutoff valves on rel ief ~ p a r a g r a p h 6221(a) ~mplles that they cannot be used except as allowed by ASME code. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Committee is of the opinion that there is no conflict between the ASME Code, 4720 and 6221(a).

59A-57 - (Chapter 6, Paragraph 6221(c), last sentence): Reject SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas Assoclat~on ~ a RECOMMENDATION: Proposed:

" . . . f i r s t circumferential weld or flange Iocate~,.." Recommended Change: " . . . f i r s t circumferential weld or flange or transltion piece

located..." SUBSTANTIATION: The addition is required ~n the case of aluminum tanks in order to permit the transition from aluminum to steel. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Not now appllcable. See Comment 53.

59A-58 - (630): Accept SUBMITTER: B. H. Bakerj~an, Public Service Electr~c and Gas ~-ompany RECOMMENDATION: Delete the recommended ~nsert and put ~n its place, "~nclud~ng ~nsulation supporting plpe," between "supports" and "whose". SUBSTANTIATION: The wording as proposed by the Committee is ambiguous and could be read to refer to a support system for the pipe ~nsulation. The wording above more clearly follows the substantiation.

I OMMITTEE ACTION: Accept intent. Amend insert,to read "~nclud~ng any ~nsulation systems used to

upport p~pe." COMMITTEE COMMENT: More clearly states Committee ~ntent. Submitters' wording does not quite solve the problem.

59A-59 - (6522): Reject SUBMITTER: Max M. Levy, Columbia LNG Corporation ~ A T I O N : Circumferential butt-welds in LNG, flammable llquld, and flatamable gas service shall be fu l ly examined by radiographlc or ultrasonic inspection, except that liquid penetrant or magnetic particle methods can be utllized for all 301nts two inches or less in nominal size, and that llquid dralns and vapor vents operating at a hoop stress of less than 20% speclfied mlnlmum yield stress need not be nondestructlvely tested prowded they have been visually inspected in accordance with 336.4.2 of ANSI B31.3.

Circumferential butt-welds on all other plplng shall be examlned In accordance with the requirements of ANSI B31.3, 1976. SUBSTANTIATION: As stated in the proposed amendment, the arbitrary llmit of slx Inches has no logical basis and the exceptlon granted for visual examination based on operating hoop stress criterla should be llmlted to llquid (drain) and gas (vent) systems whlch have a low failure potentlal wlth mlnlmal resultant consequences.

The extent and type of nondestructive examination proposed In the rewording Is conslstent wlth existlng codes where examlnation is based primarily on two items:

I) Serwce application, which includes fluid serwce (lethal, non lethal, flaF~nable, etc.) cyclic effects of the system and also temperature and pressure conditlons.

2) Joint design and application. I t ~s believed that the subject of weld ~ntegrity ~s better

,addressed in th~s manner.

COMMITTEE ACTION: Reject specific recommendation. Amend TCR Proposal 59A-58 by inserting "liquid drain and vapor

vent" between "that" and "piping" and deleting "6 inches nomnal dlameter or less and." COMMITTEE COMMENT: Committee agrees that Proposal did not a~mplish the Commlttee's intent. Amendment is needed for consistency with Proposal 59A-46 (Paragraph 600) which establlshes fundamental precept.

59A-60 ~ IChapter 6, Paragraph 6622): Reject SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas Association of America RECOMMENDATION: Proposed: ~ e r e n t i a l butt-welds shall be ful ly examined by radiographic or ultrasonic inspection, except..." .

Recommended Change: "All circumferential butt-welds shall be ful ly examined by

radiographic or ultrasonlc inspectlon I f practical wlth not less than 90% of all f~eld welds and 90% of all shop welds of each day's welds, selected at random by the inspector, shall be ful ly examined . . ." SUBSTANTIATION: The proposed change conforms to the maximum requirements for pipelines as specified in Section 192.243. The recommended change produces the same degree of quality assurance as the onerous absolute 100% requirement without the inordinate costs of accounting and malntaining records to prove the total 100% ~nspection. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: After careful consideratlon, the Committee Teels that 100% is needed with the exception noted in Comment 59.

59A-61 - (6523): Reject SUBMITTER: Max M. Levy, Columbia LNG Corporatlon RECOMMENDATION: Revlse 6523 as fellows: 6523. All so-cket welds and f11Iet welds for pressurized piping systems of LNG liquld or vapor, flammable refrigerants and flammable liquids and gases shall be fu l l y examned by 11~uld penetrant or magnetic particle inspection.

Socket welds and f i l l e t welds for all other plpin 9 shall be examined in accordance with the requirements of ANSI B31.3 1976. SUBSTANTIATION: The extent, of llquid penetrant or magnetic radiographic particle examination should be based primarily on two items:

1. Servlce applicatlon, which includes fluid service (lethal, non lethal, flammable, etc.) cycllc effects of the system and also temperature and pressure conditlons.

2. Joint design and application. The proposed revision reflects this concept which is in essence

the phllosophy used In many existlng codes and standards. I t is believed that the problem of component integrity is better addressed in this manner. ( COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Paragraph 600 fu l ly d~fines the p]plng affected.

59A-62 - (Chapter 6, Paragraph 6523): Reject SUBMITTER: Lawrence J. Ogden, Interstate N~tural Gas Association of America RECOMMENDATION: Proposed:

'~All socket welds and f111et welds shall be fu l ly examined by llquid penetrant or magnetlc partlcle inspection."

Recommended Change: "All socket--or magnetic particle ~nspect~on 7f practical wlth

not less than 90% of all f ield socket welds and f i l l e t welds and 90% of all shop socket welds or f111et welds of each day's welds, selected at random by the inspector, shall be fu l ly examined." SUBSTANTIATION: ~ Thls procedure produces the same degree of quallty assurance as the onerous 100% requirement without the inordinate costs of accounting and record keeping to prove the 100% Inspection. COMMITTEE ACTION: Reject. COMMITTEE COMMENT; See Comment 60.

5 9 A - 6 3 - (6523~: Reject SUBMITTER: B. H. Bakerjlan, Public Servlce Electric and Gas ?Fo-mpany RECOMMENDATION: Insert "on cryogenic or flammable systems", between the words "welds" and "shall". SUBSTANTIATION: I t is not necessary to test welds on non-crit ical systems, COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment 61.

3B

59A-64 - (Chapter 8, Paragraph 802)): Accept SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas Assoclatlon

RECOMMENDATION: Proposed: " . . . (2) when the composition or temperature and the density

differs, . . . " Rec~ended Change: " . . . (2) when the composition or tenvperature and density Is not

compatible, . . . " SUBSTANTIATION: As proposed the requirement would necessitate that strat i f ication prevention measures must be taken whenever there is any difference between the composition or temperature and the density of the new LNG with that in the tank. From experience there is always a small difference, therefore the change, ~ OMMITTEE ACTION: Accept.

Amend f i f t h line of TCR Proposal 59A-62 by deleting "the" and ubstituting "is not compatible" for "di f fers".

COMMITTEE COMMENT: Reconlnendation more clearly expresses intent.

SgA-fS - (g01(a)): Accept SUBMITTER: B. H. Bakerjian, Public Service Electrlc and Gas ~ p a n y

~ E~OM~IENDATION: Near the end of the sentence change the word "of" etween "refrigerants" and "flammable" to "or".

SUBSTANTIATION: Sentence does not read properly. ~OMMITTEE ACTION: Accept editorial correction.

SgA-66 - (g04-existing 902): Reject SUBMITTER: 8. H. Bakerjian, Public Service Electric and Gas ron~oany RECOMMENDATION: Delete. SUBSTANTIATION: The recommendation does not appear to have any relation to the referenced existing paragraph 902. Additionally, the substantiation does not read properly. CO~t(ITTEE ACTION: Reject specific recommendation.

"902" in f i r s t line should be "921". Editorial errors in substantiation wil l be corrected.

COMMITTEE ACTION: Reject intent. I Amend TCR Proposal 59A-81 by addlng "or Impractlcal." to the end of 940. COMMITTEE COICMENT: The Committee does not feel that "containers" should be deleted from the context of this provlslon. There are many circumstances where water protectlon of a contalner would be necessary. Where the container slze is such that cooling 1s not practical, other factors - e.g., sit ing, spacing and container design - need to be evaluated. See 901.

59A-70 - (940): Reject SUBMITTER: Joel Anderson, Southern Energy Company ~ A T I O N : Revise as follows: 940. A water supply and a system for distributing and applying water shall be provided for protection of exposures; cooling containers, equipment and piping; and controlling LNG vapor resultln9 from unign~ted leaks and spil ls; unless an evaluation in accordance with 901 indicates the use of water is unnecessary. SUBSTANTIATION: Water is not used to control LNG, but rather to control vapor from a spi l l . The recommended change clarlf les the intent. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment 68.

59A-71 - (Chapter 9, Paragraph 940): Reject SUBMITTER: Lawrence J. Ogden, Interstate Natural Gas Association o--f-X~F~-FTfa RECOMMENDATION: Proposed:

"...and controlling unignlted leaks and spil ls; ..~" Recommended Change: "...and controlling unignlted LNG vapor resulting from leaks and

spil ls; . . . " SUBSTANTIATION: Water is not used to control LNG, but rather to control vapor from a spi l l . The recommended change clarif ies the intent. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment 68.

59A-67 - (910): Accept SUBMITTER: 8. H. Bakerjlan, Public Service Electric and Gas l~'--ompany ~RECOMMENDATION: Change the recommended word "force" to "fence". SUBSTANTIATION: The use of the word "force" does not make sense in the context in which it is used. The word "fence" would appear to relate to the subject of the paragraph. ICOMMITTEE ACTION: Accept editorial correction.

5gA-fB - (940): Reject SUBMITTER: Lester V. Hebenstrelt, Kidde Bellevi l le, A Division of Walter Kidde & Co. RECOMMENDATION: Fourth llne, add "the vapors from" between "controlling" and "unignited." SUBSTANTIATION: The addition of water to an LNG pool wil l increase the boi l-off rate and the hazard; since the evolved vapors wil l remain cold; a pound of water wil l boil approximately one pound of LNG. The suggested addition ~S meant to c lar i fy how water should be used. CONMITTEE ACTION: Reject. COMNITTEE COMMENT: The recommended amendment would indlcate that water should never be applied to LNG liquid. In fact, water can be used to form ice to stop small liquid leaks and, under seqective discretionary use, may be advisable to eliminate small spil ls by increasing the vaporization rate.

59A-72 - (940): Reject SUBMITTER: 8. H. Bakerjian, Public Service Electric and Gas O---o~pany RECOMMENDATION: Delete the words "at exposures". ~UBSTANTIATION: I t is not clear what is meant by "exposures". This should therefore be deleted or a better word used. C OMMITT[E ACTION: Reject specific recommendation.

Amend TCR Proposal 59A-81 by changing "at" to "of" in 940. COMMITTEE COMMENT: The term "exposures" is common f i re protection engineering terminology. As used here, as elsewhere, i t refers to hazards controllable by use of water.

59A-73 - (941): Reject SUBMITTER: B. H. Bakerjlan, Public Service Electric and Gas ~umpany RECOMMENDATION: Delete the words ~an" and "of 63L/s (1000 gpm)" and add the words "a suitable" between the words "plus" and "allowance". SUBSTANTIATION: The blanket requirement for an addltlonal 1000 gpm o v e r ~ b o v e those already listed may be excessive in many cases. The decislon for the volume of water necessary should be lef t to the designer and local f i re protection force. COMMITTEE ACTION: Reject. COfC~ITTEE COMMENT: The Committee feels that this allowance is in order for sound design.

S9A-69 - (940): Reject SUBMITTER: Max M. Levy, Columbia LNG Corporation ~ A T I O N : Revise 940 as follows:

A water supply and a system for distributing and applying water shall be provided for protection at exposures; cooling, equipment and piping; and cOntrolllng unignited leaks and spil ls; unless an evaluation in accordance with 901 indlcates the use of water is unnecessary. SUBSTANTIATION: I t is recommended that the requirement for the cooling of containers be deleted from this proposal. The amount of water required to properly cool a large LNG storage tank from the effects of a fu l l dike f l re of an adjacent storage tank can be tremendous. I t is d i f f i cu l t to jus t i fy the addition of a massive f i re water supply and distribution system capable of delivering tens of thousands of gallons of water per minute when the accident probability is acceptably low. The probability of a massive f i re requiring cooling protection of the storage tanks is suff iciently low so as to preclude any such requirement. In addition, proposed paragraph 941 requires a minimum two hour supply, however, i f one were to consider a fu l l dike f l re the two hour supply would fa l l "considerably short in terms of the duration of the f i re. To insure a sufficient supply in this event would further increase the scope of the f i re water system for protection against a low probability accident.

59A-74 - (954): Reject SUBMITTER: Joel Anderson, Southern Energy Company ~ A T I O N : Revise as follows: 954. Plant asslgned automotive vehlcles shall be provided with a minimum of one portable dry chemical extlngulsher having a capacity of not less than 5 pounds. SUBSTANTIATION: The only need that a plant vehlcle should have for a portable extinguisher is in the unlikely event of the vehicle's engine catchln 9 f l re . A 20 pound portable unlt is oversized for such an application. I f the intent was to provide additional f i re extinguishment for an LNG spil l f i re , then these units are unnecessary. Section 951 allows for sufficient portable units to be strategically located throughout the fac i l i ty . COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Intent is not to use such extinguishers on a vehicle. Rather, provision takes advantage of the fact that plant personnel can make pro~)t and effective use of a vehicle-mounted extinguisher on a f i re detected from the vehicle.

39

5gA-75 - (9701): Reject SUBMITTER: B. H. Bakerjian, Public Service Electric and Gas ~pany RECOMMENDATION: Delete the phrase "in the vic ini ty of p r o t e c ~ l o s u r e s 'and in other areas". SUBSTANTIAT!QN: The phrase appears extraneous,and adds confusion. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee feels that perimeter lighting is needed for plant security. However, i t wil l study the matter further to see i f more specific wording can be developed.

5gA-76 - (59A-87): None required SUBMITTER: B. H. Bakerjiao, Public Service Electric and Gas ~ p a n y RECOMMENDATION: Delete, SUBSTANTIATION: I concur with the recommendation of the Committee that the suggested change be declined. With regard to ignition of a vapor cloud, i t should be noted that the New York City F~re Department Code speclflcally prohibits dellberate ignition of LNG vapor. COMMITTEE ACTION: None required. COMMI'TTEE COMMENT: Committee appreciates the accolade.

40